ML20236T646

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Discusses Commissioner Bernthal Public Comments at Baltimore-Washington Health Physics Meeting on 870422 Re Use of Byproduct Matl & Related Matters.Record of 870408 Telcon Encl.Copyrighted Mddi Repts Publication Not Filmed
ML20236T646
Person / Time
Issue date: 04/23/1987
From: Mcelroy N
NRC
To: Bernero R, Cunningham R, Thompson H
NRC
Shared Package
ML20235F951 List: ... further results
References
FRN-52FR36942, RULE-PR-35 AC65-1-022, AC65-1-22, NUDOCS 8712010425
Download: ML20236T646 (4)


Text

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APR 2 31987 NOTE T0: Hugh L. Thompson, Jr. ,

Robert M. Bernero Richard E. Cunningham Glen L. S,ioblom.

-Vandy L. Miller

? COMMISSIONER BERNTHAL'S PUBLIC COMMENTS ON THE MEDICAL USE OF BYPRODUCT MATERIAL AND 0THER MATTERS Commissioner Bernthal was the guest speaker at last night's Baltimore-Washington Health Physics Meeting. The advertized title of his talk was "10 CFR 20--Proposed Revisions."

-However, the early portion of his prepared remarks were devoted to the safe medical use of byproduct material. He reiterated his statements, made on his

" Misadministration" ballot, that there is clear benefit. from medical use, but that the inherent risk that accompanies quality medical care should not be mixed with the risk due to carelessness and inattention. He noted that the Commission will examine training criteria for all medical use workers, not just physicians, and is developing comprehensive medical use quality assurance regulations. He mentioned his personal recommendation that the NRC's jurisdiction be expanded to include accelerator-produced radiopharmaceuticals.

Regarding the regulation of power plants, he said the backfit rule was the Commission's attempt to get control of itsel f. Cost-benefit calculations that have " quality" . factors in them were characteri ed as " regulatory sleight of hand that is misleading." He also mentioned his concern that complex regulations "such as the revised Part 20" may lead to frustration and unwitting or purposeful non-compliance.

He stated that the emotional impact of TMI and Chernobyl has proven the need L for public education lest the legacy of those two events be acid rain and the i greenhouse effect. Maintenance of the nuclear option requires that there be i no erosion of public confidence in the nation's nuclear power program.

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m In response to a question, he agreed that there must be a more coherent sense of radiation risk as compared to other substance risks. This could be m accomplished by incorporating the NRC function within EPA, as is done .in many

.1 other countries.

I After the meeting, his assistant Janet Kotra made some informal, chary remarks to me. Apparently, Commissioner Bernthal played a key role in .the

, preparation of his speech, especially that portion dealing with r misadministration.

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